Air carrier pilot reported there are insufficient FAA regulations and references in flight operations manuals for ATC equipment failures that could impact multiple aircraft; especially during holding procedures for ILS approaches at EWR.

2025-05 · NASA ASRS report 2240997

Date: 2025-05 · Aircraft: Commercial Fixed Wing · Phase: approach

Anomalies: atc-issue-all-types|deviation-discrepancy-procedural-clearance|no-specific-anomaly-occurred-unwanted-situation

Synopsis

Air carrier pilot reported there are insufficient FAA regulations and references in flight operations manuals for ATC equipment failures that could impact multiple aircraft; especially during holding procedures for ILS approaches at EWR.

Narrative

ATC communication failure is a grave threat to safe operations at EWR. FOM is insufficient to meet the realities of this scenario. Existing FAA regulations and subsequent FOM references are tailored to failure of aircraft communication systems; not ATC equipment failures affecting multiple aircraft. FOM procedures suggest reaching out to Dispatch through ACARS. This is an inappropriate activity for an aircraft below 10;000 feet who has been vectored off the arrival for an approach; even more so for an aircraft below 5;000 who has multiple other aircraft in the vicinity at the same or similar altitudes all pointed towards one of the Newark ILS approaches. It is insufficient and unrealistic to suggest that even 2 or 3 inbound aircraft can all safely proceed to PATRN or KILMA and hold safely at the same altitude until an ETA; as the procedure is written. Furthermore; the procedure requires the hold to be established in the direction of a hold or procedure turn depicted on the chart. Neither the ILS 22L nor the ILS 4R contain a hold or a procedure turn. Nor does the Stadium Visual Runway 29; which is the primary approach being utilized during this period of runway construction; and remains common during the strong winds of summer. I believe a midair collision is imminent and Company management is using the insufficient procedures that always exist as a shield instead of facing this reality in order to provide better guidance or establish new protocol.

Source: NASA Aviation Safety Reporting System (public domain). Reports are voluntary submissions and are not verified by NASA.

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